Statutory Guidelines [Appendix A(3) IRC 130] regarding certain personal injury liability assignments.
Statutory Guidelines [Appendix A(3) IRC 130] regarding certain personal injury liability assignments.
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A qualified assignment simply means one that qualifies for income tax exclusion based on the criteria defined in Internal Revenue Code §§104(a)(2) and 130. Settlement proceeds from personal injury, wrongful death, and workers' compensation cases all fall under this designation.
Section 130(c) defines a qualified assignment as any assignment of liability to make periodic payments as damages (whether by suit or agreement) on account of personal injury or sickness (in a case involving physical injury or sickness) provided, among other conditions, the periodic payments are fixed and determinable
(d) Qualified funding assetFor purposes of this section, the term qualified funding asset means any annuity contract issued by a company licensed to do business as an insurance company under the laws of any State, or any obligation of the United States, if (1)
Section 130(c) defines a qualified assignment as any assignment of liability to make periodic payments as damages (whether by suit or agreement) on account of personal injury or sickness (in a case involving physical injury or sickness) provided, among other conditions, the periodic payments are fixed and determinable